Turkish Law on Personal Data Protection Clarification Text
1- What is Personal Data and Special categories of Personal Data, who processes it?
Pursuant to Article 3 of the Law on the Protection of Personal Data No. 6698, personal data means any information relating to an identified or identifiable real person. Special categories of personal data are data related to race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, disguise and clothing, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric data and genetic data. Konfrut AG Tarım Anonim Şirketi(“”Company” or “Konfrut AG”), as a “Data Controller” pursuant to the Law on Protection of Personal Data No. 6698, will be able to record, store, update, disclose and transfer your personal data that you have shared with the Company in accordance with the law, to the third parties specified in the clarification text.
2- For what purpose can your Personal Data be processed?
Konfrut AG collects your personal data in order to guarantee you an error-free registration and implementation of the application procedure within the scope of the technical possibilities of our platforms (website recruitment tool and HTS 5). There are compulsory and voluntary indications. Compulsory indications are marked with a red star.
Our obligation to process your personal data arises from the Turkish Law on Personal Data No. 6698, Turkish Employment Law No. 4857, Turkish Law of Obligations No. 6098, Turkish Criminal Code No. 5237 and the Turkish Law on Electronic Commerce No. 6563.
During registration on our recruiting platform we collect your complete fore- and surname and your mail address.
During application procedure we compulsory collect your salutation respectively gender, your complete fore- and surname, your title, employer, mail address, phone number and address. Furthermore we collect the personal data that is embodied in the documents which you upload on your own during application procedure (resume, cover letter, further documents). Furthermore we collect your date of birth, salary expectation, requested workplace, travel readiness, beginning date of work.
Beyond that we collect voluntary indications if you fill in the appropriate gaps during the application procedure. These indications refer to: foreign work experience (employer, appointment, beginning and end date of work) and course of education (school/ university, graduation/ degree, major/ branch), apprenticeship (kind of educational institution, branch), language skills, geographical preferences with regard to the working place.
In case of participation in our assessment center, we register your complete first and last name, gender and your school-leaving certificate when registering on the HTS 5 test platform. The test execution and storage of the test results takes place on the platform.
We only collect data that is strictly necessary for the registration and/ or application as well as selection procedure and only in such way that you are informed about the data collection and have given your consent therefor. We do not collect and/ or process personal data of you that is redundant. You can revoke your consent at any time. In the case of revocation we will no longer collect, process or otherwise use any of your personal data. Furthermore you can withdraw or delete your application(s). For more information please have a look at point 5.
Your data is being used for the mere purpose of the implementation of the application procedure. In order to conduct the registration on our recruiting platform as well as our test platform HTS 5 we need your complete fore- and surname and your mail address. We need your salutation respectively gender, your complete fore- and surname, your degree / your school-leaving certificate, your current employer, your mail address, your phone number and your address, your personal data that is embodied in the documents which you upload on your own during application procedure (resume, cover letter, further documents), date of birth, salary expectation, requested workplace, travel readiness, beginning date of work in order to create your applicant profile and conduct the application procedure by our recruiters after junction of the personal data you have made available. Additional personal data you provide makes it possible for us to consider your individual preferences and imaginations and these data is also being joined in your applicant profile.
Furthermore we need your data for:
- our Talent Pool (speculative application): in order to suggest you an appropriate job, if possible
3- To whom and for what purpose can your processed personal data be transferred?
We do not transmit your personal data to third parties other than the service providers of our platform and HTS 5 and government authorities. Personal data transfer purpose is parallel with data processing purpose set out in this privacy policy.
If a transmission to a third party other than the ones stated above should be necessary we ensure that we receive your expressly full consent and inform you comprehensively about the subject matter of the transmission, no transmission will take place elsewise. Besides that we will only transmit your data if we are legally bound to that. Before we transmit your data to third party other than the ones stated above we ensure that your personal data is anonymized (e.g. in order to create the average age of the applicants), that means that there is no possibility to draw conclusions about you or your person.
4- For what legal reason and by what method do we collect your personal data?
Your personal data is collected by our Company, verbally or in writing, through the forms on the website, telephone, e-mail, correspondence and similar media, for the legal reasons specified in article 2 of this Clarification Text. Your collected personal data can also be processed and transferred in accordance with the Turkish Law on Personal Data No. 6698 and for the purposes specified in the 2nd and 3rd articles of this Clarification Text.
5- What are your rights in accordance with the Personal Data Protection Law No. 6698?
Under Article 11 of the Law, by applying to Konfrut AG, you will have the right to a) learn whether your personal data is processed or not, b) request information as to personal data if it has been processed, c) learn the purpose of processing and whether the data is used in accordance with its purpose, d) learn the third parties of the transfer, in the country and abroad, e) request rectification if the data have been processed incompletely / inaccurately, f) request deletion / destruction of your personal data in accordance with Article 7 of the Law, g) request notification of the operations made as per indents (e) and (f) to third parties to whom personal data have been transferred, h) object to occurrence of any result detrimental by means of analysis of personal data exclusively through automated systems and i) request compensation for the damages due to unlawful processing of personal data.
6- How will you contact the data controller?
You can refer your information and application requests through the Application Form in the link indicated below.
[https://konfrutag.com.tr/kariyer]
Konfrut AG will conclude your requests free of charge within thirty days as of the application at the latest and as soon as possible in accordance with the nature of the claim. However, if the transaction requires a cost, a fee may be charged. We may accept and process the request or reject the request in writing by explaining the reason.
If the application is rejected by following the above mentioned procedure, replied insufficiently or not replied in due time, within thirty days from the notification date of the reply and in any case in sixty days from the date of the application you have the right to file a complaint before the Board of Protection of Personal Data (“Board”). However, complaints cannot be directed without exhausting the application remedy.
In the event of a complaint or an allegation of violation, the Board shall conduct the necessary inspection within the scope of its competence. Upon complaint, the Board reviews the request and gives a reply to those concerned. If the reply is not given within sixty days from the date of complaint, the request is deemed to be rejected. In the event of a complaint or a direct inspection, in case the Board decides that a violation exist, it shall notify the interested parties as to the decision that the data controller shall eliminate the violation. This decision shall be executed within thirty days at the latest from the notification without delay. The Board may decide to terminate the data processing or data transfer to abroad, if unrecoverable or impossible damage arises and it is a sheer violation of the Law.
7- Contact
If you have any questions regarding this Clarification Text feel free to contact us or our data controller contact person via mail or email.
Konfrut AG Tarım A.Ş.
Cevizli Mah. Zuhal Cad. Ritim İstanbul A3 Blok No:46C/182 Maltepe/İstanbul
Tel.: +90 216 545 68 68
Fax: +90 216 340 82 08
info@konfrutag.com.tr
Data Controller Contact Person
Olcay Polat
Tel: +90 216 545 68 68 / 112
olcay.polat@dohler.com.tr